When a school district defaults on its obligations to provide a student with a disability a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act, what is the standard to determine whether a parent's private placement is proper under the Act?

QUESTIONS PRESENTED 1. When a school district defaults on its obligations to provide a student with a disability a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act, 20 U.S.C. § 1400 et seg. (the IDEA), what is the standard to determine whether a parent’s private placement is proper under the Act? 2. What is the level of deference that a district court must provide to the state proceeding on the issue of whether a private school is appropriate? li RELATED CASES W.A. v. Hendrick Hudson Cent. Sch. Dist., No. 14-CV3067 (KMK), 2017 WL 3066888 (S.D.N.Y. July 18, 2017) W.A. v. Hendrick Hudson Cent. Sch. Dist., 219 F. Supp.3d 421 (S.D.N.Y. 2016) WA. v. Hendrick Hudson Cent. Sch. Dist., No. 14-CV8093 (KMK), 2016 WL 1274587 (S.D.N.Y. Mar. 31, 2016) Application of the Board of Education of the Hendrick Hudson Central School District, N.Y. State Educ. Dep't, State Review Officer, Appeal No. 14-015 (Mar. 18, 2014) Application of a Student with a Disability, N.Y. State Educ. Dep’t, State Review Officer, Appeal No. 12-138 (Jan. 31, 2014) In Matter of Impartial Hearing, Impartial Hearing Officer Findings of Fact and Decision (Dec. 17, 2013) In Matter of Due Process Complaint of W., Impartial Hearing Officer, Findings of Fact and Decision (June 21, 2012)